The Federal Communications Commission has issued a final rule aimed at further strengthening its equipment authorization program against national security risks to the communications supply chain.
The FCC’s Covered List comprises equipment and services that have been determined to pose an unacceptable risk to U.S. national security or the security and safety of U.S. persons. Equipment and services on this list are banned from receiving new FCC equipment authorizations, which are required prior to importation, marketing, or sale in the U.S.
This final rule makes the following regulatory changes.
- effective Oct. 13, prohibits authorization of devices that incorporate logic-bearing hardware components (see rule text for definition) produced by an entity identified on the Covered List if the device would itself be prohibited from authorization had the Covered List entity produced the entire device (this prohibition applies prospectively to new equipment authorization applications but does not affect previously authorized equipment)
- clarifies that the existing prohibition on permissive changes and modifications applies both to equipment that is already prohibited from authorization and to equipment that would become prohibited as a result of the proposed modification (e.g., a shift in production to a Covered List entity or a change that would cause a device to lose “domestic end product” status)
- requires that any entity on the Covered List seeking a permissive change to equipment, whether or not the equipment is itself covered, submit an application for recertification rather than relying on the more limited permissive-change process
- confirms that no Covered List entity may use the supplier’s declaration of conformity process for any modification
- clarifies that FCC marketing rules reach any entity (including online marketplaces) that markets unauthorized equipment
- requires online marketplaces, subject to limited exceptions, to display a certified device’s FCC ID at the online point of sale (compliance dates of March 1, 2027, for online marketplaces with physical access to or title over the device and June 1, 2027, for marketplaces relying on third-party seller certifications)
- amends its definition of “critical infrastructure,” as used on the Covered List
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